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7th December 2016

The Advanced Business Manager (ABM) Billfeeds Service uses a Data Extraction Service and engine supplied by Xtracta Ltd (“The Supplier”) and software developed by Concept Business Systems (“The Licencee”) to integrate the Data Extraction Service with ABM. The following Privacy Policy applies to the privacy of data passing through the Billfeeds service for ABM customers.

In addition to Xtracta Ltd, the following ABM parties may have access to information:

Concept Business Systems (“The Licencee”)

Advanced Business Manager Pty Ltd

ABM National Distributors

Authorised Support Consultants

Billfeed’s Privacy Policy

The Supplier's privacy policy is designed to protect all Personal Information that is sent to, stored and/or processed by the Data Extraction Services. This policy outlines the Supplier's policies around access to, and retention and security of, Personal Information.

Authorised Access

The Supplier will treat the Licensee and its personnel as being authorised to access any Personal Information that is sent to the Data Extraction Services under the Licensee’s account, either directly or to a further sub-organisational group. This includes Personal Information that forms part of data that is not owned by the Licensee but is sent under the Licensee's use of the Data Extraction Service (such as Personal Information that forms part of the Licensee's customers' data). It is the responsibility of the Licensee to obtain all consents and approvals that are necessary for the Licensee and its personnel to access Personal Information as described above.

The Supplier will not disseminate any Personal Information held by it to any 3rd party except:

where the Supplier has been given consent by the Licensee;

to the person whom the Personal Information is about (Data Subject) (generally personnel of the end customer and, where the end customer is an individual, the end customer him/herself), in accordance with applicable law; or

where the Supplier is otherwise required to under applicable law.

The Supplier may access or use anonymised data at any time for internal purposes such as quality assurance testing, system maintenance, artificial intelligence learning and/or internal testing.

Extensions

It is possible that there will be authorised access of Personal Information to parties beyond:

The Data Subject

The Licensee and its personnel

The Supplier and its personnel

Authorised access may be granted as needed to

Advanced Business Manager Pty Ltd

The customer’s ABM National Distributor

The customer’s authorized ABM support consultant.

The Supplier may provide information about which parties have access to Personal Information to the relevant Data Subject, in accordance with applicable law.

By using the Advanced Business Manager (ABM) Billfeeds Service, you authorize that access to Personal Information may be granted to any of the above parties.

Access

Any Personal Information forming part of the Data that is held by the Supplier will be accessible by the Licensee, the Data Subject, any party that the Licensee or the Data Subject has authorised to access it, or any party that otherwise has a legal right to have access to it. This is either through typical access methods to the Supplier's system(s) or otherwise (for example accessing deleted Personal Information forming part of data held in backup by the Supplier). Charges may apply for access to data that is no longer in the Supplier's customer facing system(s) (due to for example retrieval costs of that data).

Security of login/access information is solely the responsibility of the Licensee and the Supplier accepts no liability where the Licensee or its personnel have failed to properly secure system access leading to a disadvantageous situation for the Licensee or its personnel or customers(such as unauthorised data access).

Retention

The Data Extraction Service(s) are primarily processing based system and as such the Supplier's retention of Personal Information is generally limited. The Supplier provides no guarantees in relation to the time period that Personal Information will be retained once it enters its system(s).

Location

The Supplier's Service(s) run via a global network of computers that are located in various countries and jurisdictions. Due to the nature of the Supplier's system(s), the location for various aspects of the Licensee's data that passes through its systems will be fixed to certain locations.

The Supplier commits to providing full information on the locations and content where any aspect of the Licensee's data will be stored in relation to the fixed aspects of its system(s).

Data Security

The Supplier undertakes rigorous internal processes and has implemented strong security policies to protect all Personal Information sent, residing or being processed through its system(s). This includes standard industry practices for access management, storage, processing and transit of Personal Information.

The Supplier provides encrypted options for any data to be passed between it and 3rd parties and it highly recommends that 3rd parties utilise only these options for any data transfers.

Breaches

Where there is any breach of this privacy policy relating to Personal Information forming part of the Data, the Supplier will provide details of the breach to the Licensee as soon as reasonably practicable. This is only within its (the Supplier's) ability to understand the scope and details of a breach for example what is available within logs, audit histories etc.

DataAll data, content, and information (including Personal Information) that is captured from documents, processed or stored using the Data Extraction Services.

Data Extraction Services/TechnologyThe service(s), products, code, systems or know-how provided or to be provided by the Supplier to capture data from documents, as set out in a Service Schedule. This includes all services and intellectual property of the Supplier encompassed within the “Xtracta App” product or otherwise in regards to the provision of the Data Extraction Services exclusive of the Support Services.

Personal InformationInformation or an opinion about an identified individual, or an individual who is reasonably identifiable.

Reasonable CareThe degree of caution and concern an ordinarily prudent and rational person would use in similar circumstances.